HomeMy WebLinkAboutPacket Special Council Jun 14 2022Whatcom County
Council (Special)
COUNTY COURTHOUSE
311 Grand Avenue, Ste #105
Bellingham, WA 98225-4038
(360) 778-5010
Meeting Agenda
Tuesday, June 14, 2022
10:30 AM
Hybrid Meeting
HYBRID MEETING (PARTICIPATE IN -PERSON, SEE REMOTE JOIN
INSTRUCTIONS AT www.whatcomcounty.us/joinvirtualcouncil, OR CALL
360.778.5010)
COUNCILMEMBERS
Barry Buchanan
Tyler Byrd
Todd Donovan
Ben Elenbaas
Carol Frazey
Kaylee Galloway
Kathy Kershner
CLERK OF THE COUNCIL
Dana Brown -Davis, C.M.C.
Council (Special) Meeting Agenda June 14, 2022
Call To Order
Roll Call
Announcements
Individuals who require special assistance to participate in the Council's meetings are asked to
contact the Council Office at 360.778.5010 at least 96 hours in advance.
Committee Discussion and Recommendation to Council
1. AB2022-335 Request approval to send a letter to the State Building Code Council on
residential energy code
Items Added by Revision
Other Business
Adiournment
Whatcom County Page 2 Printed on 21912024
File ID:
AB2022-335
File Created:
05/31/2022
Department:
Council Office
Assigned to:
Council (Special)
Agenda Date:
06/14/2022
Whatcom County
Agenda Bill Report
File Number: AB2022-335
COUNTY COURTHOUSE
311 Grand Avenue, Ste #105
Bellingham, WA 98225-4038
(360)778-5010
Version: 1 Status: Agenda Ready
Entered by: MRouse@co.whatcom.wa.us
File Type: Request for Motion
Primary Contact Email: DBrown@co.whatcom.wa.us
TITLE FOR AGENDA ITEM:
Final Action: 06/14/2022
Enactment #:
Request approval to send a letter to the State Building Code Council on residential energy code
SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE:
HISTORY OF LEGISLATIVE FILE
Date: Acting Body:
Action:
06/07/2022 Council Climate Action and Natural FORWARDED TO
Resources Committee COUNCIL WITH
06/07/2022 Council
06/14/2022 Council (Special)
RECOMMENDED
MOTION(S)
Aye: 2 Donovan, and Galloway
Nay: 1 Elenbaas
DISCUSSED AND
MOTION(S) APPROVED
AMENDED AND
APPROVED BY THE
COUNCILMEMBERS
Sent To:
Attachments: Substitute letter V1, Substitute Letter V2, Dated 6.13.2022, Draft Letter, Final Letter
Whatcom County Page 1 Printed on 2/9/2024
June 17, 2022
Washington State Building Code Council
1500 Jefferson St SE
Olympia, WA 98501
Chairman Doan and Members of the State Building Code Council:
As local elected officials from Whatcom County, we write to urge the SBCC to build on your
excellent work updating the Washington state commercial energy code and now adopt a new
residential energy code for new construction that similarly aligns with our state and local
climate and sustainability goals. Specifically, we support a residential energy code that will help
transition our communities to all -electric, addressing vulnerabilities to climate change, reducing
indoor and outdoor air pollution, maximizing use of passive solar and other energy saving
technologies, and ensuring that we are building healthy, resilient, and affordable homes. By
working towards the elimination of gas appliances, particularly for space and water heating, we
can work to reduce pollution and carbon emissions from our building sector.
Statewide Clean Codes Are Needed to Support Local Government Efforts
Whatcom County is one of at least a dozen cities and counties in Washington, representing over
1.7 million people, who have developed or are implementing climate action plans' that commit
local resources to curbing dangerous greenhouse gas emissions.Z Buildings comprise the
second-largest — and fastest growing — component of our state's GHG emissions, including 29%
of Whatcom County's GHG emissions. Statewide in 2018, burning fossil fuels in Washington
buildings produced emissions equivalent to nearly 4 million cars or 5 coal plants. Washington
state is required by law to achieve a 95% reduction in emissions from 1990 levels by 20501,
and we are committed to doing our part. However, unlike with commercial construction, our
reading of state law is that cities and counties are preempted from implementing energy codes
for residential construction that are more stringent than the state's minimum requirements.
Therefore, to meet our climate commitments, we are dependent on the SBCC to act again and
require a//new buildings across the state to be clean.
Clean Codes Support Our Energy Efficiency and Climate Commitments
Washington is a leader in the clean energy economy. As we continue to move the supply side of
our grid to net zero emissions by 2030 and 100% clean electricity by 2045 as required by state
law,4 we must also target direct combustion of fossil fuels in buildings and replace combustion
with efficient electric appliances. For example, Hheat pumps,
which are 2-4 times more efficient than electric resistance or combustion gas equipment, can
and must play a significant role in keeping our state on track for the 70% reduction in energy
use that SBCC is required by law to meets
The Climate Commitment Act (CCA) passed in 2021 imposes a steadily declining cap on
greenhouse gas emissions to achieve a 95% reduction in by 2050; it will require natural gas
suppliers to acquire rapidly declining and thus increasingly expensive pollution allowances, as
gas use is phased out entirely over the coming decades. While existing gas customers will
receive some protection from rate increases under the CCA, it's critical to note that most
owners of newly constructed buildings will not.6 Continuing to add any new buildings to the gas
distribution system means locking in decades of carbon and methane emissions, and more
stranded assets for the gas industry, while condemning homeowners to greater fuel price
volatility and the likelihood of expensive retrofits in the future. To achieve our climate goals and
protect consumers, our first step must be to stop digging the hole deeper and commit to
efficient, all -electric appliances in every newly constructed building in the state.
Clean Codes Support Our Economy and Housing Costs
The 2021, Washington State Energy Strategy states that building electrification is "the least -cost
strategy" to decarbonize the building sector.' In addition, one report estimates that electrifying
our building stock would create 5,500 installation jobs in Washington and 80,000 manufacturing
jobs nationwide that our state can compete for.$
The Rocky Mountain Institute's (RMI) Economics of Electrifying Buildings study, as well as
several other studies, found that in Seattle, an all -electric home saves both money and 28 tons
Of CO2 emissions over a 15-year period.9 This is because all -electric homes are typically cheaper
to build upfront: $4,500 less than a mixed -fuel home with a gas furnace, water heater, and air
conditioning (increasingly vital in our warming climate, as evidenced by last summer's dramatic
and dangerous heat wave10). In addition, even before the recent run-up in energy prices,
exacerbated by the war in Ukraine, both the EIA and the World Bank forecast significant
increases in natural gas costs, but relatively flat electricity costs — making the economic case for
all -electric homes even stronger. Combined with the impacts of the phase -out of gas required
under the CCA, any new homes built with gas will face ever increasing energy bills and an
eventual expensive retrofit. This means that any new gas household we allow heightens the
severe risk that we are stranding those families with escalating bills. And the homes least likely
to be able to switch will be low-income households.
Clean Codes Support Healthy Homes and Communities
A recent Harvard study showed that in Washington, burning fossil fuels in buildings was
responsible for 52 premature deaths and over $577 million in health impacts in 2017, based on
just their outdoor air pollution alone. Combusting gas in furnaces, stoves and ovens releases
dangerous air pollutants like methane (CH4), nitrogen oxide (NOx), carbon monoxide (CO), fine
particulate matter (PM2.5), ultrafine particles, and formaldehyde. Another recent study
estimates "that natural gas stoves emit 0.8-1.3% of the gas they use as unburned methane"
and "using a 20-year timeframe for methane, annual methane emissions from all gas stoves in
U.S. homes have a climate impact comparable to the annual carbon dioxide emissions of
500 000 cars".11 Furthermore, Tthese pollutants can lead to a range of respiratory,
cardiovascular, and neurological health issues - children in homes with gas stoves are 42%
more likely to develop asthma symptoms.12 Health burdens related to pollution and other
environmental stressors such as extreme heat disproportionately affect low -to -moderate income
communities and communities of color. Our State Energy Strategy has pledged to address these
disparities while also ensuring the "equitable distribution of clean energy benefits and reduction
of burdens to communities highly impacted by climate change."13 The SBCC adoption of an
energy code that reduces air pollution will empower local communities like ours to repair the
historical inequities that are further aggravated by climate change. Moving away from the use
of an explosive gas to heat new buildings also reduces the risk of fire and explosions, such as
that which occurred in the Greenwood neighborhood of Seattle in 2016.14
As local elected officials, we are responsible for aFe e~ the fFent lines On responding to and
supporting our communities during extreme weather events like the recent floods, wildfires,
droughts, and heat. We are committed to help solve climate change by lowering Washington's
greenhouse gas emissions, and to adapt to its effects by making our communities healthier,
safer and more resilient. We also recognize that some communities within Whatcom County rely
more heavily on natural gas, diesel, and other fossils fuels due to vulnerabilities like frequent
power outages and proximity/lack of access to basic needs, only exacerbated by severe weather
events, flooding, and climate change. We hope that a new residential building code will allow
for a strategic transition and incorporate measures addressing vulnerabilities and increasing
community resilience.
Decisions on what and how to build always involves economic tradeoffs, such as the type of
windows, appliances, and heating and cooling systems. Most new buildings will last through this
century. Both climate change and building construction require long-term views when making
good "tradeoff" decisions. Building codes help owners make the right decisions that will save
them money in the long run. It makes less sense now to Pprolong+ng gas use in new
construction -cS} ~�-'---es ~e sense when because we have there-aFe better, cleaner, safer, and
more efficient heat pump eptienstechnoloclies available, which take advantage of
Washington's increasingly clean electrical grid.
For all the reasons mentioned above, we believe the SBCC should require all -electric new
residential construction, ensuring that our communities are sustainable, affordable equitable,
and healthy, now and in the future.
Sincerely,
1 Whatcom County Climate Action Plan:
https://www.whatcomcounty.us/DocumentCenter/View/61403/CAP-Final--20211022-ver2
2 "Cities with Climate Action Plans," Zero Energy Alliance: https://zeroenergyproject.org/all-cities-with-
climate-action-plans/
3 Washington State Legislature: https://apes.leg.wa.gov/rcw/defauIt.aspx?cite=70A.45.020
4 "Clean Energy Transformation Act" Washington State Dept. of Commerce:
https://www.commerce.wa.ciov/cirowing-the-economy/enerciy/ceta/
5 Washington State Legislature: https://app.leg.wa.gov/rcw/default.aspx?cite=19.27A.160
6 Washington State Legislature, Climate Commitment Act, Section 15(c):
https://Iawfilesext.leg_wa.gov/biennium/2021-22/Pdf/Bills/Session%20Laws/Senate/5126-S2.SL.pdf
Washington State Energy Strategy, pg. 67 (2021): https://bit.ly/3k35WOH
8 Rewiring America, "The Benefits of Electrification,": https://map.rewiringamerica.org/states/washington-
wa
9 "The New Economics of Electrifying Buildings", RMI. https://rmi.org/insight/the-new-economics-of-
electrifying-buildings
10 "Hidden Toll of the Northwest Heat Wave: Hundreds of Extra Deaths":
https://www. nytimes.com/interactive/2021/08/ 11/climate/deaths-pacific-northwest-heat-wave. html
11 "Methane and NOx Emissions from Natural Gas Stoves, Cooktops, and Ovens in Residential Homes",
Environmental Science & Technology: https://pubs.acs.org/doi/10.1021/acs.est.1c04707
12 "Meta -analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in
children", Internal Journal of Epidemiology: https://doi.org/10.1093/iie/dytl50
13 Washington State Energy Strategy, pg. 22 (2021): https://bit.ly/3kJ5WOH
14 "Seattle explosion leaves heart of Greenwood neighborhood a gigantic mess":
https://www.seattletimes.com/seattle-news/greenwood-explosion-destroys-buildings-injures-9-
firefighters/
June 17, 2022
Washington State Building Code Council
1500 Jefferson St SE
Olympia, WA 98501
Chairman Doan and Members of the State Building Code Council:
As local elected officials from Whatcom County, we believe it is important for us to share our
perspective on the impacts of a new all -electric residential energy code as we continue to weigh
the many benefits with the potential or unintended consequences. Today, we write to urge the
SBCC to build on your excellent work updating the Washington sState commercial energy code
and now adopt a new residential energy code for new construction that similarly aligns with our
state and local climate and sustainability goals. Specifically, we support a iew residential energy
code that will help tFansitien our communities aecaroonize Dy transmoning to at electric -space
and water heating, while addressing vulnerabilities to climate change, reducing indoor and
outdoor air pollution, maximizing use of passive solar and other energy saving technologies,
and ensuring that we are building healthy, resilient, and affordable homes. By working towards
the elimination of gas appliances, particularly for space and water heating, we can work to
reduce pollution and carbon emissions from our building sector.
Statewide Clean Codes Are Needed to Support Local Government Efforts
In 2021, Whatcom County adopted a Climate Action Plan', which outlines many goals,
strategies, and actions to reduce greenhouse gas emissions in the built environment. Whatcom
County is one of at least a dozen cities and counties in Washington, representing over 1.7
million people, who have developed or are implementing climate action plans' that commit local
resources to curbing dangerous greenhouse gas emissions.' Buildings comprise the second-
largest — and fastest growing — component of our state's GHG emissions, including 29% of
Whatcom County's GHG emissions. Statewide in 2018, burning fossil fuels in Washington
buildings produced emissions equivalent to nearly 4 million cars or 5 coal plants. Washington
state is required by law to achieve a 95% reduction in emissions from 1990 levels by 20504,
and we are committed to doing our part. However, unlike with commercial construction, our
reading of state law is that cities and counties are preempted from implementing energy codes
for residential construction that are more stringent than the state's minimum requirements.
Therefore, to meet our climate commitments, we are dependent on the SBCC to act again and
require al/new buildings across the state to be clean.
Clean Codes Support Our Energy Efficiency and Climate Commitments
Washington is a leader in the clean energy economy. As we continue to move the supply side of
our grid to net zero emissions by 2030 and 100% clean electricity by 2045 as required by state
law,5 we must also target direct combustion of fossil fuels in buildings and replace combustion
with efficient electric appliances. decrease the demand for energy. For example, #heat pumps,
which are 2-4 times more efficient than electric resistance or combustion gas equipment, can
and must play a significant role in keeping our state on track for the 70% reduction in energy
use that SBCC is required by law to meet.6
The Climate Commitment Act (CCA) passed in 2021 imposes a steadily declining cap on
greenhouse gas emissions to achieve a 95% reduction in by 2050; it will require natural gas
suppliers to acquire rapidly declining and thus increasingly expensive pollution allowances, as
gas use is phased out entirely over the coming decades. While existing gas customers will
receive some protection from rate increases under the CCA, it's critical to note that most
owners of newly constructed buildings will not.' Continuing to add any new buildings to the gas
distribution system means locking in decades of carbon and methane emissions, and more
stranded assets for the gas industry, while condemning homeowners to greater fuel price
volatility and the likelihood of expensive retrofits in the future. To achieve our climate goals and
protect consumers, our first step must be to stop digging the hole deeper and commit to
efficient, all -electric appliances in every newly constructed building in the state.
Clean Codes Support Our Economy and Housing Costs
The 2021, Washington State Energy Strategy states that building electrification is "the least -cost
strategy" to decarbonize the building sector.8 In addition, one report estimates that electrifying
our building stock would create 5,500 installation jobs in Washington and 80,000 manufacturing
jobs nationwide that our state can compete for.9
The Rocky Mountain Institute's (RMI) Economics of Electrifying Buildings study, as well as
several other studies, found that in Seattle, an all -electric home saves both money and 28 tons
Of CO2 emissions over a 15-year period.10 This is because all -electric homes are typically
cheaper to build upfront: $4,500 less than a mixed -fuel home with a gas furnace, water heater,
and air conditioning (increasingly vital in our warming climate, as evidenced by last summer's
dramatic and dangerous heat wave"). In addition, even before the recent run-up in energy
prices, exacerbated by the war in Ukraine, both the EIA and the World Bank forecast significant
increases in natural gas costs, but relatively flat electricity costs — making the economic case for
all -electric homes even stronger. Combined with the impacts of the phase -out of gas required
under the CCA, any new homes built with gas will face ever increasing energy bills and an
eventual expensive retrofit. This means that any new gas household we allow heightens the
severe risk that we are stranding those families with escalating bills. And the homes least likely
to be able to switch will be low-income households.
Clean Codes Support Healthy Homes and Communities
A recent Harvard study showed that in Washington, burning fossil fuels in buildings was
responsible for 52 premature deaths and over $577 million in health impacts in 2017, based on
just their outdoor air pollution alone. Combusting gas in furnaces, stoves and ovens releases
dangerous air pollutants like methane (CH4),nitrogen oxide (NOx), carbon monoxide (CO), fine
particulate matter (PM2.5), ultrafine particles, and formaldehyde. Another recent study
estimates "that natural gas stoves emit 0.8-1.3% of the gas they use as unburned methane"
and "using a 20-year timeframe for methane, annual methane emissions from all gas stoves in
U.S. homes have a climate impact comparable to the annual carbon dioxide emissions of
500000 cars".12 Furthermore, Tthese pollutants can lead to a range of respiratory,
cardiovascular, and neurological health issues - children in homes with gas stoves are 42%
more likely to develop asthma symptoms.13 Health burdens related to pollution and other
environmental stressors such as extreme heat disproportionately affect low -to -moderate income
communities and communities of color. Our State Energy Strategy has pledged to address these
disparities while also ensuring the "equitable distribution of clean energy benefits and reduction
of burdens to communities highly impacted by climate change.1114 The SBCC adoption of an
energy code that reduces air pollution will empower local communities like ours to repair the
historical inequities that are further aggravated by climate change. Moving away from the use
of an explosive gas to heat new buildings also reduces the risk of fire and explosions, such as
that which occurred in the Greenwood neighborhood of Seattle in 2016.15
Codes Must Support Resilient Communities
Over the last year alone, Whatcom County has experienced increasingly severe and frequent
effects of climate change including wildfires, heat dome, floods, and other severe weather
events. These emergencies often disproportionately impact our low income and rural
communities, exacerbating inequities and vulnerabilities. As local elected officials, we are
responsible for aFe en the fFent lanes an responding to and supporting our communities during
these extre~~e events, which we expect to become even more common and severe in
the future as climate change intensifies . We
are committed to help solve climate change by lowering Washington's greenhouse gas
emissions, and also to adapt to its effects by making our communities healthier, safer and more
resilient.
In Whatcom County, we anticipate most of our growth will be accommodated by small cities,
urban growth areas, and rural areas. These communities often experience frequent and
prolonged power outages due to severe weather events, resulting in difficulty accessing basic
needs. We want to recognize that some residents still depend on wood, natural gas, diesel, and
other fossils fuels for backup energy during power outages. As we transition to all -electric new
construction, communities must be able to prepare for emergencies and continue to build
resilience and self-sufficiency, which may require wood fireplaces or gas -powered back-up
generators in the short-term. Therefore, we urge the SBCC to allow for a strategic transition
and incorporate measures addressing vulnerabilities and increasing community resilience.
Concurrently, we are committed to working with our state and federal partners on energy grid
modernization and resiliency, investing in underground utilities, and access to affordable and
reliable electricity for all communities.
better, cleaner and safer heat pump eptiens available new, which take advantag
For all the reasons mentioned above, we believe the SBCC should require -move towards all -
electric new residential construction, ensuring that our communities are sustainable, affordable
equitable, and healthy, now and in the future.
Sincerely,
1 Whatcom County Climate Action Plan:
https://www.whatcomcounty.us/DocumentCenter/View/61403/CAP-Final--20211022-ver2
htti3s whateengeeunty.Lisie@euFneRtGenter/Vwewi61403iGAP Funnal 20211022 veF2
3 "Cities with Climate Action Plans," Zero Energy Alliance: https://zeroenergyproiect.org/all-cities-with-
climate-action-plans/
4 Washington State Legislature: https://apes.leg.wa.gov/rcw/defauIt.aspx?cite=70A.45.020
5 "Clean Energy Transformation Act" Washington State Dept. of Commerce:
https://www.commerce.wa.gov/growing-the-economy/energy/ceta/
6 Washington State Legislature: https://app.leg.wa.gov/rcw/default.aspx?cite=19.27A.160
Washington State Legislature, Climate Commitment Act, Section 15(c):
https://Iawfilesext.leg.wa.gov/biennium/2021-22/Pdf/Bills/Session%20Laws/Senate/5126-S2.SL. pdf
8 Washington State Energy Strategy, pg. 67 (2021): https://bit.ly/3k]5WOH
9 Rewiring America, "The Benefits of Electrification,": https://map.rewiringamerica.org/states/washington-
wa
10 "The New Economics of Electrifying Buildings", RMI. https://rmi.org/insight/the-new-economics-of-
electrifying-buildings
11 "Hidden Toll of the Northwest Heat Wave: Hundreds of Extra Deaths":
https://www. nytimes.com/interactive/2021/08/ 11/climate/deaths-pacific-northwest-heat-wave. html
12 "Methane and NOx Emissions from Natural Gas Stoves, Cooktops, and Ovens in Residential Homes",
Environmental Science & Technology: https://pubs.acs.org/doi/10.1021/acs.est.1c04707
13 "Meta -analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in
children", Internal Journal of Epidemiology: https://doi.org/10.1093/ije/dytl50
14 Washington State Energy Strategy, pg. 22 (2021): https://bit.ly/3kJ5WOH
15 "Seattle explosion leaves heart of Greenwood neighborhood a gigantic mess":
https://www.seattletimes.com/seattle-news/greenwood-explosion-destroys-buildings-injures-9-
firefighters/
June 17, 2022
Washington State Building Code Council
1500 Jefferson St SE
Olympia, WA 98501
Chairman Doan and Members of the State Building Code Council:
As local elected officials from Whatcom County, we write to urge the SBCC to build on your
excellent work updating the Washington state commercial energy code and now adopt a new
residential energy code that similarly aligns with our state and local climate and sustainability
goals. Specifically, we support a residential energy code that will help transition our
communities to all -electric, reducing indoor and outdoor air pollution and ensuring that we are
building healthy, resilient, and affordable homes. By working towards the elimination of gas
appliances, particularly for space and water heating, we can work to reduce pollution and
carbon emissions from our building sector.
Statewide Clean Codes Are Needed to Support Local Government Efforts
Whatcom County is one of at least a dozen cities and counties in Washington, representing over
1.7 million people, who have developed or are implementing climate action plans' that commit
local resources to curbing dangerous greenhouse gas emissions.2 Buildings comprise the
second-largest — and fastest growing — component of our state's GHG emissions, including 29%
of Whatcom County's GHG emissions. Statewide in 2018, burning fossil fuels in Washington
buildings produced emissions equivalent to nearly 4 million cars or 5 coal plants. Washington
state is required by law to achieve a 95% reduction in emissions from 1990 levels by 20503,
and we are committed to doing our part. However, unlike with commercial construction, our
reading of state law is that cities and counties are preempted from implementing energy codes
for residential construction that are more stringent than the state's minimum requirements.
Therefore, to meet our climate commitments, we are dependent on the SBCC to act again and
require a//new buildings across the state to be clean.
Clean Codes Support Our Energy Efficiency and Climate Commitments
Washington is a leader in the clean energy economy. As we continue to move the supply side of
our grid to net zero emissions by 2030 and 100% clean electricity by 2045 as required by state
law,4 we must also decrease the demand for energy. Heat pumps, which are 2-4 times more
efficient than electric resistance or combustion gas equipment, can and must play a significant
role in keeping our state on track for the 70% reduction in energy use that SBCC is required by
law to meets
The Climate Commitment Act (CCA) passed in 2021 imposes a steadily declining cap on
greenhouse gas emissions to achieve a 95% reduction in by 2050; it will require natural gas
suppliers to acquire rapidly declining and thus increasingly expensive pollution allowances, as
gas use is phased out entirely over the coming decades. While existing gas customers will
receive some protection from rate increases under the CCA, it's critical to note that most
owners of newly constructed buildings will not.6 Continuing to add any new buildings to the gas
distribution system means locking in decades of carbon and methane emissions, and more
stranded assets for the gas industry, while condemning homeowners to greater fuel price
volatility and the likelihood of expensive retrofits in the future. To achieve our climate goals and
protect consumers, our first step must be to stop digging the hole deeper and commit to
efficient, all -electric appliances in every newly constructed building in the state.
Clean Codes Support Our Economy and Housing Costs
The 2021, Washington State Energy Strategy states that building electrification is "the least -cost
strategy" to decarbonize the building sector.' In addition, one report estimates that electrifying
our building stock would create 5,500 installation jobs in Washington and 80,000 manufacturing
jobs nationwide that our state can compete for.$
The Rocky Mountain Institute's (RMI) Economics of Electrifying Buildings study, as well as
several other studies, found that in Seattle, an all -electric home saves both money and 28 tons
Of CO2 emissions over a 15-year period.' This is because all -electric homes are typically cheaper
to build upfront: $4,500 less than a mixed -fuel home with a gas furnace, water heater, and air
conditioning (increasingly vital in our warming climate, as evidenced by last summer's dramatic
and dangerous heat wave10). In addition, even before the recent run-up in energy prices,
exacerbated by the war in Ukraine, both the EIA and the World Bank forecast significant
increases in natural gas costs, but relatively flat electricity costs — making the economic case for
all -electric homes even stronger. Combined with the impacts of the phase -out of gas required
under the CCA, any new homes built with gas will face ever increasing energy bills and an
eventual expensive retrofit. This means that any new gas household we allow heightens the
severe risk that we are stranding those families with escalating bills. And the homes least likely
to be able to switch will be low-income households.
Clean Codes Support Healthy Homes and Communities
A recent Harvard study showed that in Washington, burning fossil fuels in buildings was
responsible for 52 premature deaths and over $577 million in health impacts in 2017, based on
just their outdoor air pollution alone. Combusting gas in furnaces, stoves and ovens releases
dangerous air pollutants like nitrogen oxide (NOx), carbon monoxide (CO), fine particulate
matter (PM2.5), ultrafine particles, and formaldehyde. These pollutants can lead to a range of
respiratory, cardiovascular, and neurological health issues - children in homes with gas stoves
are 42% more likely to develop asthma symptoms." Health burdens related to pollution and
other environmental stressors such as extreme heat disproportionately affect low -to -moderate
income communities and communities of color. Our State Energy Strategy has pledged to
address these disparities while also ensuring the "equitable distribution of clean energy benefits
and reduction of burdens to communities highly impacted by climate change."12 The SBCC
adoption of an energy code that reduces air pollution will empower local communities like ours
to repair the historical inequities that are further aggravated by climate change. Moving away
from the use of an explosive gas to heat new buildings also reduces the risk of fire and
explosions, such as that which occurred in the Greenwood neighborhood of Seattle in 2016.11
As local elected officials, we are on the front lines in responding to and supporting our
communities during extreme weather events like the recent floods, wildfires, droughts, and
heat. We are committed to help solve climate change by lowering Washington's greenhouse
gas emissions, and to adapt to its effects by making our communities healthier, safer and more
resilient.
Prolonging gas use just makes no sense when there are better, cleaner, safer, and more
efficient heat -pump options available now, which take advantage of Washington's increasingly
clean electrical grid.
For all the reasons mentioned above, we believe the SBCC should require all -electric new
residential construction, ensuring that our communities are sustainable, affordable equitable,
and healthy, now and in the future.
Sincerely,
1 Whatcom County Climate Action Plan:
https://www.whatcomcounty. us/DocumentCenter/View/61403/CAP-Final--20211022-ver2
z "Cities with Climate Action Plans," Zero Energy Alliance: https://zeroenergyproject.org/all-cities-with-
climate-action-plans/
3 Washington State Legislature: https://apps.leg.wa.gov/rcw/defauIt.aspx?cite=70A.45.020
4 "Clean Energy Transformation Act" Washington State Dept. of Commerce:
https://www.commerce.wa.gov/growing-the-economy/energy/ceta/
5 Washington State Legislature: https://app.leg.wa.gov/rcw/default.aspx?cite=19.27A.160
6 Washington State Legislature, Climate Commitment Act, Section 15(c):
https://Iawfilesext.leg.wa.gov/biennium/2021-22/Pdf/Bills/Session%20Laws/Senate/5126-S2.SL.pdf
Washington State Energy Strategy, pg. 67 (2021): https://bit.ly/3k]5WOH
8 Rewiring America, "The Benefits of Electrification,": https://map.rewiringamerica.org/states/washington-
wa
9 "The New Economics of Electrifying Buildings", RMI. https://rmi.org/insight/the-new-economics-of-
electrifying-buildings
10 "Hidden Toll of the Northwest Heat Wave: Hundreds of Extra Deaths":
https://www. nytimes.com/interactive/2021/08/11/climate/deaths-pacific-northwest-heat-wave. html
11 "Meta -analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in
children", Internal Journal of Epidemiology: https://doi.org/10.1093/ije/dytl50
12 Washington State Energy Strategy, pg. 22 (2021): https://bit.ly/3kJ5WOH
13 "Seattle explosion leaves heart of Greenwood neighborhood a gigantic mess":
https://www.seattletimes.com/seattle-news/greenwood-explosion-destroys-buildings-injures-9-
firefighters/
CLERK OF THE COUNCIL
Dana Brown -Davis, C.M.C.
COUNTY COURTHOUSE
311 Grand Avenue, Suite #105
Bellingham, WA 98225-4038
(360) 778-5010
WHATCOM COUNTY COUNCIL
June 14, 2022
Washington State Building Code Council
1500 Jefferson St SE
Olympia, WA 98501
Chairman Doan and Members of the State Building Code Council:
COUNCILMEMBERS
Rud Browne
Barry Buchanan
Tyler Byrd
Todd Donovan
Ben Elenbaas
Carol Frazey
Kathy Kershner
As local elected officials from Whatcom County, we believe it is important for us to
share our perspective on the impacts of a new all -electric residential energy code as
we continue to weigh the many benefits with the potential or unintended
consequences. Today, we write to urge the State Building Code Council (SBCC) to
build on your excellent work updating the Washington State commercial energy code
and now adopt a new residential energy code for new construction that similarly
aligns with our state and local climate and sustainability goals. Specifically, we
support a new residential energy code that will help our communities decarbonize by
transitioning to electric space and water heating, while addressing vulnerabilities to
climate change, reducing indoor and outdoor air pollution, maximizing use of passive
solar and other energy saving technologies, and ensuring that we are building
healthy, resilient, and affordable homes. By working towards the elimination of gas
appliances, particularly for space and water heating, we can work to reduce pollution
and carbon emissions from our building sector.
Statewide Clean Codes Are Needed to Support Local Government Efforts
In 2021, Whatcom County adopted a Climate Action Plan', which outlines many goals,
strategies, and actions to reduce greenhouse gas emissions in the built environment.
Whatcom County is one of at least a dozen cities and counties in Washington,
representing over 1.7 million people, who have developed or are implementing
climate action plans that commit local resources to curbing dangerous greenhouse
gas emissions.2 Buildings comprise the second-largest - and fastest growing -
component of our state's GHG emissions, including 29% of Whatcom County's GHG
emissions. Statewide in 2018, burning fossil fuels in Washington buildings produced
emissions equivalent to nearly 4 million cars or 5 coal plants. Washington state is
required by law to achieve a 95% reduction in emissions from 1990 levels by 20501,
and we are committed to doing our part. However, unlike with commercial
construction, our reading of state law is that cities and counties are preempted from
implementing energy codes for residential construction that are more stringent than
the state's minimum requirements. Therefore, to meet our climate commitments,
we are dependent on the SBCC to act again and require a// new buildings across the
state to be clean.
1
Clean Codes Support Our Energy Efficiency and Climate Commitments
Washington is a leader in the clean energy economy. As we continue to move the
supply side of our grid to net zero emissions by 2030 and 100% clean electricity by
2045 as required by state law,4 we must also target direct combustion of fossil fuels
in buildings and replace combustion with efficient electric appliances. For example,
heat pumps, which are 2-4 times more efficient than electric resistance or combustion
gas equipment, can and must play a significant role in keeping our state on track for
the 70% reduction in energy use that SBCC is required by law to meets
The Climate Commitment Act (CCA) passed in 2021 imposes a steadily declining cap
on greenhouse gas emissions to achieve a 95% reduction by 2050; it will require
natural gas suppliers to acquire rapidly declining and thus increasingly expensive
pollution allowances, as gas use is phased out entirely over the coming decades.
While existing gas customers will receive some protection from rate increases under
the CCA, it's critical to note that most owners of newly constructed buildings will not.'
Continuing to add any new buildings to the gas distribution system means locking in
decades of carbon and methane emissions, and more stranded assets for the gas
industry, while condemning homeowners to greater fuel price volatility and the
likelihood of expensive retrofits in the future. To achieve our climate goals and protect
consumers, our first step must be to stop digging the hole deeper and commit to
efficient, all -electric appliances in every newly constructed building in the state.
Clean Codes Support Our Economy and Housing Costs
The 2021, Washington State Energy Strategy states that building electrification is
"the least -cost strategy" to decarbonize the building sector.' In addition, one report
estimates that electrifying our building stock would create 5,500 installation jobs in
Washington and 80,000 manufacturing jobs nationwide that our state can compete
fo r.8
The Rocky Mountain Institute's (RMI) Economics of Electrifying Buildings study, as
well as several other studies, found that in Seattle, an all -electric home saves both
money and 28 tons of CO2 emissions over a 15-year period.9 This is because all -
electric homes are typically cheaper to build upfront: $4,500 less than a mixed -fuel
home with a gas furnace, water heater, and air conditioning (increasingly vital in our
warming climate, as evidenced by last summer's dramatic and dangerous heat
wave10). In addition, even before the recent run-up in energy prices, exacerbated by
the war in Ukraine, both the EIA and the World Bank forecast significant increases in
natural gas costs, but relatively flat electricity costs - making the economic case for
all -electric homes even stronger. Combined with the impacts of the phase -out of gas
required under the CCA, any new homes built with gas will face ever increasing
energy bills and an eventual expensive retrofit. This means that any new gas
household we allow heightens the severe risk that we are stranding those families
with escalating bills. And the homes least likely to be able to switch will be low-income
households.
Clean Codes Support Healthy Homes and Communities
A recent Harvard study showed that in Washington, burning fossil fuels in buildings
was responsible for 52 premature deaths and over $577 million in health impacts in
2
2017, based on just their outdoor air pollution alone. Combusting gas in furnaces,
stoves and ovens releases dangerous air pollutants like methane (CH4), nitrogen
oxide (NOx), carbon monoxide (CO), fine particulate matter (PM2.5), ultrafine
particles, and formaldehyde. Another recent study estimates "that natural gas stoves
emit 0.8-1.3% of the gas they use as unburned methane" and 'using a 20-year
timeframe for methane, annual methane emissions from all gas stoves in U.S. homes
have a climate impact comparable to the annual carbon dioxide emissions of 500,000
cars".11 Furthermore, these pollutants can lead to a range of respiratory,
cardiovascular, and neurological health issues - children in homes with gas stoves
are 42% more likely to develop asthma symptoms.12 Health burdens related to
pollution and other environmental stressors such as extreme heat disproportionately
affect low -to -moderate income communities and communities of color. Our State
Energy Strategy has pledged to address these disparities while also ensuring the
`equitable distribution of clean energy benefits and reduction of burdens to
communities highly impacted by climate change."73 The SBCC adoption of an energy
code that reduces air pollution will empower local communities like ours to repair the
historical inequities that are further aggravated by climate change. Moving away from
the use of an explosive gas to heat new buildings also reduces the risk of fire and
explosions, such as that which occurred in the Greenwood neighborhood of Seattle
in 2016.14
Codes Must Support Resilient Communities
Over the last year alone, Whatcom County has experienced increasingly severe and
frequent effects of climate change including wildfires, heat dome, floods, and other
severe weather events. These emergencies often disproportionately impact our low
income and rural communities, exacerbating inequities and vulnerabilities. As local
elected officials, we are responsible for responding to and supporting our
communities during these events, which we expect to become even more common
and severe in the future as climate change intensifies. We are committed to help
solve climate change by lowering Washington's greenhouse gas emissions, and also
to adapt to its effects by making our communities healthier, safer and more resilient.
In Whatcom County, we anticipate most of our growth will be accommodated by small
cities, urban growth areas, and rural areas. These communities often experience
frequent and prolonged power outages due to severe weather events, resulting in
difficulty accessing basic needs. We want to recognize that some residents still
depend on access to wood, natural gas, diesel, and other fossil fuels for energy when
homes have limited, or no access caused by such things as power outages, severe
weather, or location. The lack of traditional energy sources such as these can create
life threatening situations where individuals have no, or limited, ability to heat their
homes, prepare food, or access essential communications. As we transition to all -
electric new construction, communities must be able to prepare for emergencies and
continue to build resilience and self-sufficiency, which may require wood fireplaces
or gas -powered back-up generators in the short-term. Therefore, we urge the SBCC
to allow for a strategic transition and incorporate measures addressing vulnerabilities
and increasing community resilience. Concurrently, we are committed to working
with our state and federal partners on energy grid modernization and resiliency,
investing in underground utilities, and access to affordable and reliable electricity for
all communities.
3
For all the reasons mentioned above, we believe the SBCC should move towards all -
electric new residential construction, ensuring that our communities are sustainable,
affordable, equitable, and healthy, now and in the future.
Sincerely,
Councilmember Barry Buchanan
Councilmember Tyler Byrd
Councilmember Todd Donovan
Councilmember Carol Frazey
Councilmember Kaylee Galloway
Councilmember Kathy Kershner
*Please note: Councilmember Ben Elenbaas was opposed to sending
this letter and declined to sign
C: Correspondence File
AB2022-335
1 Whatcom County Climate Action Plan:
https://www.whatcomcounty.us/DocumentCenter/View/61403/CAP-Final--20211022-ver2
2 "Cities with Climate Action Plans," Zero Energy Alliance: https://zeroenergyproject.org/all-cities-with-
climate-action flans/
3 Washington State Legislature: https://apps.leg.wa.gov/rcw/defauIt.aspx?cite=70A.45.020
4 "Clean Energy Transformation Act" Washington State Dept. of Commerce:
htt s: /www.commerce.wa.gov/growing-the-economy/energy/ceta/
5 Washington State Legislature: https://app.leq wa.gov/rcw/defauIt.aspx?cite=19.27A.160
6 Washington State Legislature, Climate Commitment Act, Section 15(c):
ems://Iawfilesext.leq wa.gov/biennium/2021-22/Pdf/Bills/Session%20Laws/Senate/5126-S2.SL.pdf
7 Washington State Energy Strategy, pg. 67 (2021): https://bit.ly/3kJ5WOH
8 Rewiring America, "The Benefits of Electrification,": https://map.rewiringamerica.org/states/washington-
wa
9 "The New Economics of Electrifying Buildings", RMI. https://rmi.or_ /g insight/the-new-economics-of-
electrifying-buildings
to "Hidden Toll of the Northwest Heat Wave: Hundreds of Extra Deaths":
https://www.nytimes.com/interactive/`2021/08/1 I /cl i m ate/death s- pacif ic- northwest- h eat -wave. htm I
11 "Methane and NOx Emissions from Natural Gas Stoves, Cooktops, and Ovens in Residential Homes",
Environmental Science & Technology: https://pubs.acs.org/doi/10.1021/acs.est.1c04707
12 "Meta -analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in
children", Internal Journal of Epidemiology: httr)s://doi.org/10.1093/`i e d t150
13 Washington State Energy Strategy, pg. 22 (2021): https://bit.ly/3kJ5WOH
14 "Seattle explosion leaves heart of Greenwood neighborhood a gigantic mess":
https: //www.seattletimes.com/seattle-news/greenwood-explosion-destroys-buildings-injures-9-
firefighters/
111